Directive (EU) 2024/927 of 13 March 2024 (“AIFMD II”) requires that asset management companies select at least two liquidity management tools for UCITS and open-ended AIFs. By way of derogation, funds authorised under Regulation (EU) 2017/1131 on money market funds (the “MMF Regulation”) must select at least one liquidity management tool.
In this regard, in response to a question from the Association Française de la Gestion Financière (AFG) and following analysis work to which the Autorité des Marchés Financiers (AMF) contributed, the Autorité des Normes Comptables (the French Accounting Standards Authority, ANC) clarified, in a letter dated 8 July 2026, that the presence of a liquidity management tool, such as swing pricing, does not call into question the presumption of the eligibility of variable net asset value (VNAV) money market funds, whether standard or short-term, for classification as “cash equivalents”.
However, this presumption is still rebuttable, particularly during periods of market stress and in the event that such a tool is triggered.
The AMF’s guide on money market funds will be updated and will, in particular, incorporate this ANC position.